The Revenue Ruling 2004-86 issued by the IRS governs how the DST should be structured so that the purchase of a DST will fit within the guidelines of a 1031 exchange. Corcapa works with sponsors of DST offering who structure the offerings with a legal opinion for 1031 exchange purchases. We recommend that you discuss this with your tax and legal advisors and we will provide all documentation to these advisors to use in analyzing your replacement property options. Further, we are not aware of any of our clients to have ever had an IRS tax issue with the purchase of a DST investment.